- 9 - where its application would be contrary to any treaty obligation of the United States in effect on the date of enactment of the 1954 Code. See S. Rept. 100-445 at 316-328 (1988), hereinafter referred to as 1988 Senate Report). More recently, Congress had specifically provided from time to time that it intended certain amendments of the Internal Revenue Code to prevail over treaties in case of a conflict. Id. In TAMRA, Congress amended section 7852(d) to provide that neither a provision of a treaty nor a law of the United States affecting revenue shall have preferential status by reason of its being a treaty or a law. TAMRA sec. 1012(aa)(1), 102 Stat. 3531. Congress intended this change to place treaties and revenue statutes on the same footing, so that conflicts in their provisions would be resolved under the rule that the provision adopted later-in-time controls. 1988 Senate Report, supra at 321-322. Congress also intended this change to codify the approach of the courts under which the same canons of construction applied to the interaction of two statutes enacted at different times would be applied to the interaction of revenue statutes and treaties enacted and entered into at differenct times. Id. at 321. In addition to amending section 7852(d), Congress enacted the following provision as section 1012(aa)(2) of TAMRA:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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